Privacy policy

EMERY EN LIGHTENMENT CY LTD (“Company”, “our”, “we” or “us”) provides its customers and potential customers (“you”, “User”, “your”) with access to its website located at https://emeryenglish.com/ (the “Website”). Your privacy is important to us, and so is being transparent about how we collect, use, and share information about you. This Privacy Policy (the “Privacy Policy”) is intended to help you understand our practices regarding the information we may collect from you when you use and interact with the Website and when you subscribe to our products and services, including the types of personal information collected, the purpose and manners in which we may use such information, how we use the information we collect and the choices and rights available to you.

By accessing the website, you agree to the terms and conditions set forth in this privacy policy, including the collection and processing of your personal information (as defined below) as further set forth under this policy. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this Privacy Policy.

We may update our Privacy Policy to reflect changes to our information practices, new services, or relevant laws. The “Last updated” version of this Policy indicates when this Policy was last revised. Any changes are effective when we post the revised Policy on the Services.

This Privacy Policy explains how we collect, use and share your personal data: through the registration process

Categories of information we collect about you include:

• Personal information includes name and surname, email, date of birth, username, address, country, time zone and User password (encrypted);
• Optional information includes profile image;

We use this information for certain activities, including:

• For internal analysis and research.
• To help us improve our product and services.
• To collect statistical data and other information and/or other conclusive information that is non-personal.
• For communication with you to perform the services, which may include, but are not limited, by sending a link via email to authenticate you.
• To create new products and services.
• To administrate our platform, investigating any complaints, issues and providing customer service.
• For detecting and managing the activity of fraudulent and other bad-intended Users, and to seek to secure our services and transactions against unauthorized access, use, modification or misappropriation of Personal Data, information and funds.

We use this information for certain activities, including:

• It is necessary to perform our obligations or exercise our contractual rights;
• It is necessary to comply with applicable laws or regulations;
• It is necessary to provide the Users with technical assistance and support.

Categories of information we collect about you include:

We collect Personal Data via: 

• Tech Specs: including the browser, device type, operating system, screen size, script errors, IP address, country of the user.
• Learning Activity: Session progress, answers, user dictionary, user video.

We use this information for certain activities, including:

• Personalizing the experience of our website.
• Administering our website.
• Performing analysis to improve the user experience and performance of our products.
• Providing better, more customized client service.
• Detecting and preventing fraudulent and/or unlawful use of our products and services, including user-provided review content.

We use this information because:

• It is necessary to perform our obligations or exercise our contractual rights as explained in our Terms of use.
• It is necessary to provide the Users with technical assistance and support.

Categories of information we collect about you include:

• We collect payment and billing information when you register for certain paid Services. 
• For example, we ask you to provide payment information, such as payment card details, which we collect via secure payment processing services.

We use this information for certain activities, including:

• We use this personal data to process your payment and to prevent fraudulent transactions.
• Operate our business.

We use this information because:

• It is necessary to perform our obligations or exercise our contractual rights.

Categories of information we collect about you include:

• Technical information about your device, regional information 

We use this information for certain activities, including:

• Customizing our services.
• Measuring the overall effectiveness of our online content, advertising campaigns, and products and services we offer through the Product. 
• Making the website work efficiently and to collect information about your online preferences.  
• Allowing us to count users who have visited our pages.

We use this information in order to:

• Comply with our contractual obligations towards you.

Categories of information we collect about you include:

• Information you provide when you enter your data on our website, such as contact details, answer online questionnaires, or feedback forms.
• Information you provide when you subscribe to email newsletters such as name and surname, email address, and username. 
• Information you provide when registering for a member account.
• When you link your Emery.world account with your, Facebook or Google profile, we collect information from your profile, including your profile photograph.
• URLs of webpages visited when you use EMERY EN LIGHTENMENT CY LTD product.

We use this information for certain activities, including:

• Enabling you to access your account across devices.
• Personalizing your experience of our website.
• Administering our website, extension, and apps.
• Internal analysis and research to help us improve our existing products and services; and create new products and services.
• Providing more customized client service.
• Investigating complaints.
• Monitoring social media content to manage relations with our clients and promote our business.

We use this information because:

• It is necessary to perform our obligations or exercise our contractual rights as explained in our Terms of Use.

Categories of information we collect about you include:

Creating an account with Emery.world will give you access to the “content-sharing” feature and function, namely “Talk to Emery”. Using this feature, you may upload to the Emery.world site your videos and/or audio recordings (the “Content”). Categories of information we collect about you include:

• information you provide during your use of the “Talk to Emery” tool.
• Content that may be provided to Emery and distributed to the Tutor for professional evaluation of your educational progress. 
• The personal information you voluntarily disclose in the Content. 
• Your name, email address and the video or audio itself.
• If you choose to upload the Content, you agree to its evaluation by a representative of Emery.world.

We use this information because:

• You have explicitly consented to the processing of your personal data for the purpose of using the service “Talk to Emery”. You explicitly consent to the processing of your image via video and audio recording.

Categories of information we collect about you include:

• Information you provide during your request to talk to the Language Facilitator, such as your nickname, your native language and profile avatar (if you choose to upload one).
• The  Language Facilitator will not have any access to see any other information from your profile, such as your name, phone number, or email address but during your discussions, you may choose to share personal information if you wish.
• EMERY EN LIGHTENMENT CY LTD holds the right to record and store the conversations you have with the Language Facilitator for internal Website purposes and tracking your progress. By agreeing with this policy, you grant EMERY EN LIGHTENMENT CY LTD your permission, to record and store your conversations with the Language Facilitator. We do this to improve our quality of service and monitor your learning progress. In any case, EMERY EN LIGHTENMENT CY LTD does not have the right to share these recorded classes externally for any reason.

We use this information for certain activities, including:

• Improving the quality of your interactions with the Language Facilitator.
• Internal research purposes.
• Tracking your educational progress.
• Enhancing the quality of Tutor training.

We use this information because:

• It is necessary to perform our obligations or exercise our contractual rights.
• We continually strive to improve our services.

We may disclose your personal information to third parties as follows:

• To EMERY EN LIGHTENMENT CY LTD group companies to process the data for providing you with our product and services.
• When we have your consent to do so.
• To third parties who provide services for us and other IT databases, e.g., Server provider which we use to process personal information. 
• To comply with applicable laws and respond to lawful requests from public authorities.
• In the event of a corporate change, for example if EMERY EN LIGHTENMENT CY LTD is merged, sold, or in the event of a transfer of some or all of our assets, or, in connection with such a transaction and subject to applicable law, or for pre-transaction review in relation to such transactions.

Your personal information may be shared if we anonymize and/or aggregate it, as in these circumstances, the information will cease to be personal information.

Right to access and update your personal information:

• You have the right to access personal information we hold about you and to request to receive a copy of your personal data we keep. 
• You also have the right to update or correct any data we hold about you.
• You can manage your account settings at https://app.emeryenglish.com/account to update, amend, and correct your information.

Right to restrict the use of your personal data:

• You have the right to object to us processing data relating to you.
• Where you have given us consent to process your personal data, you have the right to withdraw that consent at any time.
• The above will apply until we have taken steps to verify whether we have compelling legitimate grounds to continue processing.

Right to opt-in to receive promotional material:

• You have the right to accept to our use of your personal information for marketing purposes and receive marketing material. In the event that you no longer wish to receive marketing material you have the right to unsubscribe from this service by following the steps listed in our emails. 
• You may also object to the processing of your personal information. Provided that this is not necessary for us to carry out our contractual and/or legal obligations.

Right to request deletion of your personal information:

• To delete your account with emeryenglish.com, follow the instructions available through the Service. Here: https://app.emeryenglish.com/account.

Right to complain to supervisory authorities:

• If you object to our processing of your personal information, you have the right to complain to the data protection authority (“DPA”) in the country where you reside.
• Please contact our Data Protection Officer (“DPO”) at the following address: dpo@emerylight.com to be directed to the relevant DPA.
• You may also have the right to make a GDPR complaint to the relevant Supervisory Authority. A list of EEA Supervisory Authorities is available here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm. 
• In some cases, our ability to maintain your rights may depend upon our obligations to process personal information for security, audit, safety, tax, legal, fraud prevention reasons, compliance with regulatory or legal requirements, or because processing is necessary to deliver our contractual services.

Recorded Communications:

• We may ask to record calls for research purposes. All recordings will be treated as confidential. 
• If you do not want us to record your call, you will be given a chance to opt out.

How long do we store personal data?

• If your account is blocked due to non-payment or delayed payment, your personal data is retained by us for two (2) years. We keep your personal information to allow you to restore your account if desired.
• While your account is blocked, we retain anonymized data, including data about your activity and learning progress, which may be used for internal research and may be shared with third parties. 
• No personal data is retained when your account is deleted, and your learning progress will be lost.

Children under the age of digital consent:

• Our product and services are for individuals who are at least 13 years old. If you are under the age of 13, please do not submit any personal information in our platform. We do not knowingly collect personal information from children under 13. However, if we become aware that a child under 13 has provided us with personal information, we will take steps to delete such data. 
• If you become aware that a child has provided us with personal information, please contact the support team (support@emeryenglish.com).
• In some jurisdictions, the age of consent is 13 years old and over.  If you live in one of those jurisdictions,  you must be at least that age to use our products. If this applies to you, you should review this text with your parents or guardians to ensure you understand it. We take all appropriate measures to verify your age, requiring all new subscribers to confirm that they have reached 13 years of age.

If you do not confirm the statement that you have reached 13 full years, we will not be able to fulfill our contractual obligations and provide you with access to our products and services.

If you do not provide personal information which is required (i.e. age or Date of Birth), we will not be able to perform our contractual obligations or provide you access to our products and services.

Information security:

• We have implemented administrative and technical security measures to help prevent unauthorized access. 
• Despite these measures, no data transmission over the Internet can be entirely secure, and we cannot warrant the security of any information you transmit to us. 
• A determined attacker could defeat those safeguards and may, as a result, gain access to the data we seek to protect.
• You are responsible for maintaining the security of your credentials used to access any of our services or account, and you must report suspected unauthorized activity to us.

August 17th, 2023